MEMORANDUM

Subject: Estimating E0 Volume Sold in the U.S. at marinas

From: Lester Wyborny, U.S. EPA, Office of Transportation and Air Quality

To: EPA Air Docket EPA-HQ-OAR-2015-0111

All recreational marine engines are currently produced and certified to operate on both 

E0 and E10. The number of older marine engines that were certified to operate only on E0 is in 

the extreme minority. Demand for E0 among owners of recreational marine engines is driven 

primarily by concerns about potential water contamination, the phase separation that occurs with 

ethanol blends, and the resulting engine damage. For smaller watercraft that are commonly 

trailered to launching sites, gasoline is generally purchased from retail stations that by and large 

only offer E10. Thus to the degree that there are sales of E0 to owners of recreational marine 

engines, it will occur primarily at marinas.

Stakeholders have communicated to the EPA that various entities make non-ethanol 

blended gasoline (E0) for sale at marinas. EPA has also heard from stakeholders that many 

marinas receive requests from boat owners for E0 gasoline, and in many cases, the local 

suppliers try to satisfy the boat owners’ requests. Because EPA was unable to find a direct

estimate, publicly available or otherwise, of the volume of E0 sold at marinas, we conducted an 

analysis to estimate E0 sold at marinas for purposes of determining the applicable standards 

under the RFS program. 

A number of U.S. marinas are represented by the Association of Marina Industries 

(AMI). According to AMI’s website (marinaassociation.org/), AMI represents several hundred

marinas, boatyards, yacht clubs, public/private mooring basins, partner associations and marine 

industry vendors and suppliers across the U.S. and the world. The AMI webpage also states that 

38 million gallons of fuel was sold from the marinas they represent in 2010. 

In discussions with representatives from AMI, we were told that AMI represents 500 

marinas in the U.S. and many of those marinas sell fuel, although some do not. The 38 million 

gallons of fuel sold at the marinas they represent includes both gasoline and diesel fuel, but the 

AMI did not know how much of each. Also, the 38 million gallon figure reported by AMI is the 

result of a survey, and AMI did not know what fraction of total fuels sales at their marinas the 38 

million gallons represents, because some marinas did not respond to the survey even though they 

sell fuel. We asked AMI if there was a way for them to estimate the volume of gasoline sold at 

its marinas and AMI did not believe that there was any way to do that from the data that they had 

on hand. AMI referred us to ValvTect, a company which markets additives for marine fuel at the 

AMI member marinas. 

ValvTect produces additives designed to be blended into marine gasoline and diesel fuel. 

Their additives help to prevent corrosion, stabilize the fuels, provide some detergent qualities,

and help to control the effects of moisture, thus allowing the use of ethanol-blended gasoline by 
boats if that is the fuel available. Their additives are blended into the E0 and ethanol-blended 

fuels used at 640 marinas across the US, out of the estimated 3000 marinas which sell fuels. At 

the marinas which use their additives, both gasoline and diesel fuels are marketed. Some sell 

only a small amount of fuel, while others sell a significant amount of fuel. ValvTect believes 

that the marinas at which their additives are used tend to be representative of all marinas in the 

U.S. and ValvTect estimated the volume of gasoline sold at those marinas is 50 million gallons 

per year. ValvTect could not provide an estimate of the total volume of gasoline sold at all US 

marinas. We estimated the total gasoline sold at all marinas by applying a ratio of 3000 to 640 to 

the estimated 50 million gallons of gasoline sold at the marinas that ValvTect sells its marine 

gasoline additives. Based on this methodology, we estimate that the total volume of marine 

gasoline sold in the U.S. is on the order of 248 million gallons.

In response to our questions regarding the amount of marine gasoline sold as E0, 

ValvTect replied that not all gasoline sold at marinas is E0. Marine gasoline is likely to contain 

ethanol when only gasoline blendstocks (rather than finished fuels) are available in the area, such 

as renewable blendstocks for oxygenate blending (RBOB) or conventional blendstock for 

oxygenate blending (CBOB). Conversely, finished gasoline which receives a 1 psi waiver and is 

simply splash blended with ethanol could be sold as E0. Based on this information from 

ValvTect, we estimated the fraction of marine gasoline which is E0 versus E10. 

We estimated the volume of marine gasoline sold in each state based on the number of 

marinas in each state. Marinas.com provides the number of marinas in each state, which we 

summarized in the table below. 

Estimated number of Marinas by State*

State

# of 

Marinas State

# of 

Marinas

Alabama 35 Montana UC

Alaska UC Nebraska UC

Arizona 1 Nevada UC

Arkansas 2 New Hampshire 15

California 468 New Jersey 438

Colorado 1 New Mexico UC

Connecticut 255 New York 900

Delaware 21 North Carolina 128

Dist. of Columbia 6 North Dakota UC

Florida 970 Ohio 243

Georgia 33 Oklahoma 1

Hawaii 19 Oregon 57

Idaho 1 Pennsylvania 33

Illinois 74 Rhode Island 153

Indiana 12 South Carolina 65

Iowa UC South Dakota UC

Kansas UC Tennessee 27
Kentucky 34 Texas 67

Louisiana 19 Utah UC

Maine 277 Vermont 34

Maryland 428 Virginia 185

Massachusetts 394 Washington 303

Michigan 414 West Virginia UC

Minnesota 11 Wisconsin 151

Mississippi 18 Wyoming UC

Missouri 8

*The term UC means “under construction” meaning that data collection is incomplete

For some states, information is not provided for the number of marinas and the website uses the 

term “under construction” (UC) to indicate this. It is likely that for most of these states, there are 

very few marinas in the entire state, or perhaps none, because they are states without a coastline 

and contain few lakes. The exception to this is Alaska which has a very long coastline, although 

a very small population. Counting only those states for which Marinas.com provides a value, 

there are a total of 6,301 marinas in the U.S.

To estimate the volume of marine gasoline which is E10 versus E0, we added up the 

number of marinas in predominantly Reformulated Gasoline (RFG) states, which includes 

California, Connecticut, Delaware, District of Columbia, Maryland, Massachusetts, New Jersey, 

New York, and Rhode Island. While a substantial volume of conventional gasoline is sold in 

New York, this is offset by the many other states which include some RFG areas (but where 

RFG is not predominant), including Arizona, Georgia, Illinois, Indiana, Kentucky, Louisiana, 

New Hampshire, Pennsylvania, Texas, and Wisconsin. However, the RFG volume is either 

small relative to the total gasoline sold in these states, or these states have a fewer number of 

marinas. Using this method, we estimate that the volume of marine gasoline in predominantly 

RFG states is about half of the total marine gasoline sold. Thus, the volume of E0 is estimated to 

be about half of the estimated 248 million gallons of marine gasoline sold in the U.S., which we 

calculated to be 124 million gallons. This volume of E0 is equivalent to about 128 million 

gallons of E10. Thus, the use of E0 rather than E10 at marinas reduces the nationwide total 

volume of ethanol consumed by about 13 million gallons.